Whistleblowing

The companies Corman S.p.A. and Logicor S.r.l. have adopted a Whistleblowing Reporting Management System that provides specific communication channels for the receipt and management of reports, including anonymous ones, of alleged irregularities as reported in the Whistleblowing Report Management Procedure.

All employees and collaborators of Corman S.p.A. and Logicor S.r.l., as well as all other subjects who interact with the Companies, are invited to report any violation relevant to the purposes of the Procedure of which they become aware, at any stage of their relationship with the Group Companies.

Communication channels and report content

Reports must be submitted through the following channels:

Internal reporting channels:

  • via a Digital Platform accessible from any PC, tablet or smartphone using this link: https://gruppocorman.integrityline.com.
    It is recommended that the whistleblower periodically access the platform to check for any clarification requests related to the submitted report.
  • by paper mail, addressed to the Supervisory Body of the relevant Company at the following addresses:
    – Corman S.p.A. Via Liguria, 3, 20084 Lacchiarella (MI) or
    – Logicor S.r.l. Via Liguria, 3, 20084 Lacchiarella (MI).
    The report must be submitted in two sealed envelopes: the first containing the reporting party’s identity information and a copy of their ID (unless the report is anonymous); the second containing the report. Both envelopes must then be placed in a third sealed envelope marked on the outside with “Reserved to the Company’s Report Manager xx”.
  • by means of a verbal meeting with the Supervisory Body of the Company concerned, to be arranged by email at the following addresses:
    – per Corman S.p.A. odv@corman.it.
    – per Logicor S.r.l. odv@logicor.it.

We renew our invitation to use the Digital Platform, unless it cannot be accessed for technical reasons, because:

  • the use of alternative channels cannot guarantee the same level of protection for the reporting person and efficiency in the processing of reports;
  • in the case of anonymous reports, the use of the Digital Reporting Channel is the only way to ask the whistleblower for clarification whilst maintaining their anonymity.

Only for reports concerning Corman S.p.A., external reporting channels are also provided (to be used on a residual basis and only if the requirements indicated in the Whistleblowing Procedure are met):

  • Public disclosure, i.e. making information about violations publicly available through the press, electronic media or any other means of dissemination capable of reaching a large number of people;
  • reporting to ANAC (National Anti-Corruption Authority) through i) the platform available at this link https://whistleblowing.anticorruzione.it/#/, ii) verbal report with operator call iii) face-to-face meeting or other arrangements made available by ANAC;
  • Report to the judicial or accounting authority.

The report may concern:

  • unlawful conduct relevant under Legislative Decree 231/2001 and violations of Model 231;
  • offences falling within the scope of European Union or national legislation, or national acts implementing European Union legislation, in the following areas: public procurement; services, products and financial markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety and animal health and well-being; public health; consumer protection; privacy and protection of personal data; security of networks and information systems;
  • acts or omissions affecting the Union’s financial interests;
  • acts or omissions affecting the internal market (e.g. competition and state aid infringements);
  • acts or behaviour which defeat the object or purpose of Union legislation;
  • potential or actual breaches of regulations designed to prevent money laundering and terrorist financing.

Guarantee of anonymity and prohibition of retaliation

The Companies guarantee the confidentiality of the identity of the whistleblower and any other information from which such identity may be directly or indirectly inferred.

The subjects of the report will be protected both in terms of the confidentiality of the reports concerning them and of any investigations carried out, as well as against any retaliatory and/or defamatory reports.

Retaliatory, harassing or discriminatory acts, whether direct or indirect, for reasons directly or indirectly related to the report are expressly prohibited; this protection is guaranteed to the whistleblower even if the report, although unfounded, is based on criteria of good faith and reasonableness.

Failure to comply with the procedure and its provisions may result in disciplinary action.

Persons responsible for receiving and managing reports

The management of the reporting channels is entrusted to the Report Managers designated in the Supervisory Body of Corman S.p.A. and in the Supervisory Body of Logicor S.r.l.

Response times

An acknowledgement of receipt will be sent to the reporting person within 7 days of receipt of the report.

The report will be inspected within 3 months of the date of the acknowledgement of receipt, or within 6 months in the case of an external report, if justified and reasoned.

Report archiving and retention

The data retention period is set at 5 years from the end of the reporting procedure, as provided for by art. 14 paragraph 1 of Legislative Decree 24 of 2023.

Documents produced by Corman S.p.A. and Logicor S.r.l.

As required by EU Regulation No. 679 of 2016 (so-called GDPR) and Legislative Decree 24 of 2023, the companies have adopted the following documents:

  • Co-ownership agreement pursuant to Article 26 of the GDPR between Corman S.p.A. and Logicor S.r.l., which share the same whistleblowing reporting channels, an extract of which is made available to the interested parties (extract of co-ownership agreement);
  • Notice pursuant to Article 13 of the GDPR explaining the processing of the whistleblower’s data (Whistleblower Notice);
  • Notice pursuant to Art. 13 of the GDPR explaining how the data of the person concerned is processed (Data Subject Notice);
  • Impact assessment pursuant to Article 35 of the GDPR concerning data processing operations related to the management of the reporting channels used;
  • Procedure for the management of whistleblowing reports.

The Group Companies have appointed the suppliers who carry out processing operations on their behalf as data processors pursuant to art. 28 of the GDPR and have appointed the persons authorised to receive and follow up on reports pursuant to art. 29 of the GDPR.